Case Digest (G.R. No. 242656)
Facts:
Rowena Santos y Comprado and Ryan Santos y Comprado v. People of the Philippines, G.R. No. 242656, August 14, 2019, Supreme Court Second Division, Caguioa, J., writing for the Court. Petitioners Rowena Santos y Comprado (Rowena) and Ryan Santos y Comprado (Ryan) were charged by information on September 22, 2010 with violations of Section 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). Two separate informations alleged possession of shabu: one sachet (0.1 g) found at Rowena’s residence (Crim. Case No. 2010-0410) and six sachets (about 2.8 g) found at Ryan’s residence (Crim. Case No. 2010-0411). Both pleaded not guilty.The prosecution’s account, summarized by the Regional Trial Court (RTC), recounts execution of search warrants on September 20, 2010 by a police team coordinated with PDEA and attended by mandatory witnesses (a DOJ representative, media, and a barangay official). Officers searched Rowena’s house and, in the presence of the mandatory witnesses and the accused, marked and inventoried items including a plastic sachet of shabu found in a coin purse atop the refrigerator and other cash and cellphones; at Ryan’s adjacent dwelling officers found six sachets in a blue box inside a cabinet and a large amount of cash. The seized items were photographed, inventoried, turned over through the investigating officer to the crime laboratory, and tested positive for dangerous drugs.
The defense told a different story: police entered unannounced, detained family members in the sala while searches occurred; petitioners claimed they did not personally witness the finding or opening of certain containers, denied ownership of many seized items, and emphasized that other family members had access to common areas (including the refrigerator) and that Ryan rarely occupied his separate dwelling. They refused to sign the inventory. No allegation of planting was pressed at the time.
In a Joint Judgment dated April 20, 2017, the RTC convicted both petitioners beyond reasonable doubt of illegal possession under Section 11 of RA 9165 and imposed respective indeterminate terms of imprisonment and fines...(Pro-only)
Issues:
- Did the Court of Appeals err in affirming the convictions of petitioners for violation of Section 11, Article II of RA 9165?
- Did the Court of Appeals err in finding that petitioners were in constructive possession of the illegal drugs found i...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)